As we approach the end of Q2 for 2023, the phased implementation of Packaging Extended Producer Responsibility (EPR) in the UK is in full swing. Obligated producers are mandated to begin preparing for phase 2 of the new system through the collection of granular packaging data.
To assist business in preparing for EPR, Clarity has put together the following guide on what you need to do in order to comply with UK EPR for 2023.
Obligated businesses are mandated to collect detailed packaging data from 1st March 2023. Under Producer Responsibility, obligated businesses will already be collecting some packaging data ahead of the final submission in April 2023 however, the information needed for the first EPR submission in October, which you will submit to your compliance scheme in August, requires additional granularity.
You must collect packaging data on:
Some businesses are required to collect nation of sale data, this data will be submitted in August 2024 for the time period of January-December 2023.
In 2024, Defra will introduce an eco-modulation system where hard-to-recycle packaging materials will incur a higher waste management fee than to easy-to-recycle materials which will have a reduced fee under EPR. Defra have not yet released specific information on what the modulation levels are, Clarity will ensure that all members are informed at every stage of legislative change and will be updated as soon as Defra have released this information.
Despite minimal information on modulated fees, it is encouraged that you begin reviewing and optimising your packaging format now by introducing easy-to-recycle materials into your packaging as well as reducing your packaging overall.
As well as modulated fees being introduced in 2024, in 2025 there will also be an introduction of mandatory recycling labelling. Begin preparing for these changes now in order to avoid added costs further down the line.
Once you have collected and recorded your packaging data in the desired EPR format, you must submit this data to your compliance scheme in August 2023. This will be for the time period of January-June 2023.
The first Extended Producer Responsibility for packaging data submission must include:
This is how you put the packaging on the market and what your role was when you put the packaging on the UK market. This is split up into different activities, these are:
This is recorded in the categories of:
This is recorded in the categories of:
This is recorded in the categories of:
Following your first submission you are required to continue to collect detailed packaging data ahead of the second submission to your compliance scheme in February 2024.
To ensure you are compliant with Extended Producer Responsibility, you must continue to purchase packaging (export) recovery notes (P(E)RNs). Although many businesses will have already been purchasing recycling evidence to comply with the Producer Responsibility Regulations, EPR has a single point of compliance which levies 100% responsibility. This means that there are some businesses who will no longer be obligated under legislation around packaging, and others that were not obligated before. To check if you’re obligated, use of free online obligation checker tool below.
Once you have registered with the SA, submitted packaging data to your compliance scheme in August and you have purchased the appropriate amount of recycling evidence, you have met the legal requirements for 2023 Extended Producer Responsibility!
Your local authority waste management fee and SA administrative payments will begin from 2024.
If you have unanswered questions about EPR compliance, please contact us on 0845 129 7177 or info@clarityenv.eu. A member of our expert team will contact you as soon as possible.